We are updating our Privacy Policy.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE EUROPEAN ECONOMIC AREA (EEA).

Who We Are

We are Kura Aviation C.I.C. (referred to herein as “Kura Aviation” “We”, “Us”, or “Our”). We provide training, selection and resourcing solutions to pilots and airlines (which we collectively refer to in this Privacy Policy as the “Services”) including, for example, the Airline Jet Transition course (AJT).

Our Privacy Policy describes how we collect and process your Personal Data and Sensitive Personal Data (collectively referred to as “Data”). We encourage you to read this Privacy Policy.

Information About Your Personal Data

This Privacy Policy relates to data about you and your interaction with our Services. “Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, and address. “Sensitive Personal Data” includes information concerning your racial or ethnic origin, physical or mental health, sexual life or details of criminal convictions.

We may create anonymous data from Personal Data by excluding data components (such as your name, email address) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymised and de-identified data is not subject to this Privacy Policy.

How We Collect and Use Data

We collect your Data in several ways and for various purposes, including:

When you register at an event, including, but not limited to, “Airline Pilot Training” (APT)

When you communicate with us or sign up for promotional materials

When you participate in special activities or programs

When you engage with our online communities or advertising

When you access third party products and services

When you connect with us through social media

When we collect data from third parties or publicly-available sources

When we aggregate or centralise data

When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes

How We Disclose Data

We may disclose your Data for the purposes as described in the prior section of this Privacy Policy and in the following ways:

To Affiliates and Partners

To Service Providers and Vendors

To Social Network Providers

For Advertising and Marketing

For Certain Analytics and Improvement

For Legal Compliance, Law Enforcement, and Public Safety Purposes

The types of companies with whom we share data include, but are not limited to:

Airline Recruitment

Accredited Training Organisations

Consent as a Basis for Processing

In some cases, we will ask for your consent to process your Data. You may indicate your consent in several ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Data through our Services or a form; or (ii) registering with us. We may request your consent for several activities including:

Kura Aviation Marketing and Communication

Sharing with Third Party Services

Third Party Marketing

Processing Sensitive Personal Data

Research

Advertising

To Enable Social Sharing and Connect with Us on Social Media

Promotions

Legal Basis for Processing

This section addresses the legal basis for processing your data. For the purposes of applicable data protection laws, Kura Aviation is the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, We process the Data We maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Data, or if you have questions regarding this Privacy Policy, please contact us at [email protected].

a.If you elect not to provide Data

You may choose not to provide Kura Aviation with your Data. However, if you choose not to provide your Data, you may not be able to enjoy the full range of Services.

b. How to exercise your rights

Kura Aviation takes steps to keep your Data accurate and up to date. If you reside in the European Economic Area, you have certain rights to the Data that we have collected about you. To exercise your rights to your Personal Data, please contact us through [email protected]. Subject to applicable law and in exceptional circumstances only, we may charge for this service and we will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law.

You have the following rights:

Right of access to your Data (Art. 15 GDPR): You have the right to ask us for confirmation on whether we are processing your Data, and to access the Data and related information on that processing (e.g., the purposes of the processing, or the categories of Data involved).

Right to correction (Art. 16 GDPR): You have the right to have your Data corrected, as permitted by law.

Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Data, as permitted by law. This right may be exercised among other things: (i) when your Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR and where there is no other legal ground for processing; (iii) when you object to processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Art. 21 (2) GDPR; or, (iv) when your Data has been unlawfully processed.

Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Data is contested; when the processing is unlawful, and you oppose the erasure of your Data and request the restriction of the use of your Data instead; or when you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of Kura Aviation override your grounds.

Right to data portability (Art. 20 GDPR): You have the right to receive the Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.

Right to object (Art. 21 GDPR): You have the right to object to our processing of your Data, as permitted by law. This right is limited to processing based on Art. 6 (1) (e) or (f) GDPR, and includes profiling based on those provisions, and processing for direct marketing purposes. After which, we will no longer process your Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

c. How we may disclose your Data

The GDPR and national laws of European Union member states implementing the Regulation permit the sharing of Data relating to users who are residents of the European Economic Area with third parties only under certain circumstances. If you reside in the European Economic Area, we will only share your Data as described in our Privacy Policy under the heading “How We Disclose Data” if we are permitted to do so under applicable European and national data protection laws and regulations.

d. Marketing communications

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. You may revoke your consent at any time (this will not affect the processing of your Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do so at any time as outlined in the “Managing and Withdrawing Consent” section.

e. Additional use of Data

Additional use of your Data that is not described in this Privacy Policy will only take place as required by statute or when we have obtained your consent.

f. Legal Basis for Processing under the GDPR

In this section we provide information on the legal basis for our processing of your Data as required by Art. 13 and 14 of the GDPR:

When you register or interact with our Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

When you provide Sensitive Data within our Services, including criminal convictions and VISA restrictions, as defined in the GDPR, we process such data on the basis of your prior consent, Art. 9(2)(a) GDPR.

For Personal Data which we need in order to perform the Services,such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

With regard to other Personal Data, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance our Services.

When you communicate with us or sign up for promotional materials, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with our promotional messages. Where we are required under applicable local law to obtain your consent for sending you marketing information, the legal basis is your consent, Art. 6(1)(a) GDPR.

When you participate in special activities or programs.

For Sensitive Data, we process such data on the basis of your prior consent, Art. 9(2)(a) GDPR.

For Personal Data,we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with our promotional messages or to allow you to participate in our special activities, or programs.

When you access third party products and services and we obtain Data about you from such third-party sources:

For Personal Data that we need in order to perform the Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

With regard to other Personal Data,we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to enhance your experience and to improve our Services.

When you connect with us through social media:

Where we collect your consent in such case,for instance for marketing purposes, we process such data on the basis of your prior consent, Art. 6 (1) (a) GDPR.

Where we do not collect your consentin such case, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is providing you with better Services and to enable you to use the full range of our Services (Art. 6 (1) (f) GDPR).

When we collect data from third parties or publicly-available sources:

For Personal Data which we need in order to perform the Services, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR.

With regard to other Personal Data,we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is providing you with better Services and to enable you to use our Services more efficiently.

When we aggregate or centralize data, such processing is either necessary for the performance of our Services, Art. 6 (1) (b) GDPR, or we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with better or customized Services and marketing.

When we disclose Personal Data to our affiliates and partners, and to our service providers and vendors:

Where we collect your consentin such case, we process such data on the basis of your prior consent, Art. 6 (1) (a) GDPR

Where we do not collect your consentin such case, such processing is necessary for the performance of our Services, Art. 6 (1) (b) GDPR, or we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to provide you with better Services and marketing.

When we investigate suspected illegal or wrongful activity, we process such data on the basis of our legitimate interest, Art. 6 (1) (f) GDPR, and our legitimate interest is to ensure compliance with legal requirements and law enforcement requests and for public safety purposes.

Right to lodge a complaint before the Data Protection Authority

We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Data relating to you infringes applicable data protection laws.

Changes to this Privacy Policy

In order to enhance our Services it might be necessary to change this Privacy Policy from time to time. We therefore reserve the right to modify this Privacy Policy in accordance with the applicable data protection laws.

How to contact us

In case of questions about the processing of your Personal Data please contact us at [email protected]

If we are required under applicable law to appoint a data protection officer (DPO), you can contact the DPO that is responsible at [email protected]

Managing and Withdrawing Consent

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it.

Data Retention

We will retain your Data for a period of 3 years following the signature of a training agreement or as otherwise necessary to provide you the Services. We will also retain your Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we no longer need to process your Data for the purposes set out in this Privacy Policy, we will delete your Data from our systems.

Where permissible, we will also delete your Data upon your request through [email protected]

We implement appropriate technical and organisational safeguards to protect against unauthorized or unlawful processing of Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Data.

Other Organisations

Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide access to Third Parties. We have no control over, do not review, and are not responsible for Third Parties or any goods or services available through the Third Parties. Our Privacy Policy does not apply to Third Parties, and any data you provide a Third Party, you provide at your own risk. We encourage you to review the privacy policies of any Third-Party with that you interact with.

Children

We do not knowingly collect Data online from children under 13 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Data without parental consent, please contact us through [email protected]. If we become aware that a child under 13 has provided us with Data without parental consent, we will take steps to remove the data.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through [email protected], +44 (0) 1789 298 582, or write to us at: Bruce Lodge, Bishopton Lane, Stratford-upon-Avon, Warwickshire, CV37 9QY, UK.